Financial Crimes Enforcement Network United States ol?tlte Trmqury BSAR Transcript BSA and DCN: Filing Information Type of Report Continuing Activity Report Correct/Amend Report - Prior BSA ID Filing Date 02/1 9/201 4 Received Date 02/19/2014 Entry Date 02/20/201 4 Submission Method Electronic discrete filing Subject Information Role Subject 1 oft LIMITED Subject Subject Type Other Individual/Organization Organization Last (or Entity) Name WCM777 LIMITED TIN Unknown Yes Form(s) of Identification Identification Unknown Yes The enclosed information was collected and theory-mm. 5311. at eeq; 31 CFQ Chapter X. The Information aen investigation or proceeding. 0 in the conduct at :z'trc?Il'rjence no. 1512*." a I . - u. the SSA. See USO. . witn a criminal, tax, or regulatory . 51-31 1? The information cannot be United States BSAR Tran BSA Financial Crimes Enforcement Network Department the Subject Information Address(es) Address 1 of 6 Street Address RM 1204 I2IF GREENFIELD TOWER OF CONCORDIA SCI MUSEUM FID City KOWLOON ZIP Code Unknown Yes Country HK HK - Enhanced Address 2 of 6 Street Address Unknown Yes City KOWLOON KOWLOON - Enhanced ZIP Code Unknown Yes Country HK HK - Enhanced Address 3 of 6 Street Address 150 S. LOS FIOBELS AVE STE 900 150 8 LOS ROBLES AVE STE 900 - Enhanced City PASADENA PASADENA - Enhanced State CA CA - Enhanced ZIP Code 91101 91101-2486 - Enhanced Country US US - Enhanced Address 4 of 6 Street Address City Unknown Yes ZIP Code ZIP Code Unknown Yes Country CH CN - Enhanced Address 5 of 6 Street Address HONG KONG HONG KONG - Enhanced City HONG KONG HONG KONG - Enhanced ZIP Code Unknown Yes seq. 31 CFR Chaptet Investigation (Ir er?ceequ In VII (Herd: e31. :ent iIIg BSA. CL: :3 II S. L-. II- tax :?egulamry .- ISI. 'natiun canl'IIoI PE ?=vsa Financial Crimes Enforcement Network United States Department ofthc Treasury BSAR Transcriptn BSA Subiect Information Address 5 of 6 Country CH CN - Enhanced Address 6 of 6 Street Address 1218 JOHN REED CT 1218 JOHN REED CT - Enhanced City CITY OF INDUSTRY CITY OF INDUSTRY - Enhanced State CA CA - Enhanced ZIP Code 91745 91745-2404 - Enhanced Country US US - Enhanced Phone Number(s) Type Number Work Relationship to Reportin lnstitution(s Institution TIN Relationship of Subiect Other: Yes CLIENT The enclose-d information was ?re?ected and din .33? iLJl; i?IeI released rJi seeminaied diar?Iomu 0. Iran; I. wi?iIm-r IJIIc-ior pm re nIJEati- ms mpipr?nrntinc the ESA. See 31 S. 3.319: nt a c. II Jinel rent. or i I. TI 9 Information cannot L-e .1. -.J dLiegi rate. an. it:- lie I Ciivitv repIr are ?ied tinder Financial Crimes Enforcement Network United Snitcs Treasury FinC EN BSAR Transcriptnd Subject Information Affected Account(s] Account 1 of 23 Account Number Account 2 of 28 Account Number Financial Institution TIN Account 3 of 28 Account Number Closed Financial Institution TIN Account 4 of 28 Account Number Financial Institution TIN Account 5 of 28 Account Number Financial Institution TIN Account 6 of 28 Account Number Financial Institution TIN Account 7 of 28 Account Number Financial Institution TIN Account 8 of 28 Account Number Financial Institution TIN Account 9 of 28 Account Number Financial Institution TIN Account 10 of 28 Account Number Financial Institution TIN Account 11 of 28 Account Number Financial Institution TIN Page 4 Th?; 5' ed reunllr? .Ied an." It-w'A. .S.C. 0. regulatory . .. . in mm C. he eri 1:5 Lair: i Iut?. ar: tiviiv rec 0. Is filed rider Financial Crimes Enforcement Network United State?; of'tiic Tl?t?d? BSAR Transcript BSA: and DCN: Subiect Information Account 12 of 28 Account Number Financial Institution TIN Account 13 of 28 Account Number Financial Institution TIN Account 14 of 28 Account Number Financial Institution TIN Account 15 of 28 Account Number Financial Institution TIN Account 16 of 28 Account Number Financial Institution TIN Account 17 of 28 Account Number Financial Institution TIN Account 18 of 28 Account Number Financial Institution TIN Account 19 of 28 Account Number Account 20 of 28 Account Number Financial Institution TIN Account 21 of 28 Account Number Financial Institution TIN Account 22 of 28 Account Number Financial Institution TIN Trie al'lcloseu inim?maiinri was ail-2% sic-semi: miter}. _et seq; 31 CFR tar on I din- BSA. See 31 USIF. =i with a tax. :3 The infanma egulaassy activity report: irui be led under Financial Crimes Enforcement Network United States Department oFrhc BSAR Transcript BSA: and DON: Subject Information Account 23 of 28 Account Number Financial Institution TIN Account 24 of 28 Account Number Financial Institution TIN Account 25 of 28 Account Number Financial Institution TIN Account 26 of 28 Account Number Financial Institution TIN Account 27 of 28 Account Number Financial Institution TIN Account 28 of 28 Account Number Financial Institution TIN Suspicious Activity Information Amount Involved $15,418,933 Cumulative Amount $21,435,264 Date or Date Range of Activity 04/18/2013 - 01/13l2014 Money laundering Suspicious EFT/wire transfers Fraud Other: Potential Ponzi Scheme Involvement Other suspicious activities Transaction with no apparent economic, business, or lawful purpose Financial instrument or payment Funds transfer mechanism Activity Location a a . . No Branch Activity Involved Yes Type of Financial Institution Depository institution Tile ?nds-start was mileciet. ii. ii r4311. srq. Chapter X. impairing. or in the an. mum-sm- I'll-cuuhnl - Hl'c?rllru Hid:- be Financial Crimes Enforcement Network United States Dc'pamnent ofrhc 'I'reimrj.? I BSAR Transcript BSA: and DON: Activity Location lator OCC RSSD Number 413208 Name HSBC BANK NATIONAL ASSOCIATION EIN RSSD Number 413208 Address(es) Street Address 1800 TYSONS BLVD. SUITE 50 1800 TYSONS BLVD STE 50 - Enhanced City MCLEAN MC LEAN - Enhanced State VA VA - Enhanced ZIP Code 22102 22102-4267 - Enhanced Country US US - Enhanced Internal Control File Number Filer Information Pri lator OCC Filer Name HSBC BANK NATIONAL ASSOCIATION EIN Address(es) Street Address 1800 TYSONS BLVD. SUITE 50 1800 TYSONS BLVD STE 50 - Enhanced City MCLEAN MC LEAN - Enhanced State VA VA - Enhanced ZIP Code 22102 22102-4267 Enhanced Country US US - Enhanced of Financial Institution RSSD Number 413208 Internal control/file number Contact for Assistance Full Phone Number .811.aisaq ClapteI X.T Page 7 Tm a info n. alim. :?dF (?Illa led; an 2: ui: ear allng-g {it -. ta:- my '1 he admit; ramme- under ?=vsa Financial Crimes Enforcement Network United States Department of the Trmsu BSAR Transcript and Ms Law Enforcement Information No Law Enforcement Information Available Narrative This is being written to amend a prior SAR filed on 10/29/2013 and to report on continuing activity in filed on 10/29/2013. The accounts for WCM777 LIMITED were reviewed and activity was found both predating the initial and continuing after its filing. FOR prior SAR filed on 10/29/2013 reported on activity occurring between 07/22/2013 and 10/08/2013, totaling $6,016,331.03. This activity occurred in the account of WCM777 LIMITED, a client of HSBC Hong Kong. HSBC Hong Kong is a correspondent banking client of HSBC USA NA (HBUS). The was filed because The counterpartys and their relationship to the focal in this case are unable to be determined, as well as an economic purpose could not be discovered. Potential negative news has been located on the subject for Ponzi activity. A timely review of the account in question indicates that activity similar to that reported in the initial occurred predating the initial SAR. Specifically, between 04/18/2013 and 06/28/2014 the focal entity was involved in 13 suspicious transactions totaling $200,400.00. The activity is suspicious as the relationship between the focal entity and the counterparties are unable to be determined. as well as having no discernable economic purpose, and because the focal entity is involved in a sensitive industry with negative news pending. A timely review of the account in question was conducted and it was observed that the activity leading to the writing of the initial has been continuing. Specifically between 10/09/2013 and 01/13/2014 the account in question conducted 1178 transactions totaling 15,218,532.82. The activity is suspicious as the relationship between the focal entity and the counterparties are unable to be determined, as well as having no disoernable economic purpose, and because the focal entity is involved in a sensitive industry with negative news pending. The aggregate total of new activity reported in this SAR is $15,418,932.82. The activity is suspicious because the relationship between the focal entity and the counterparties are unable to be determined, as well as having no discernable economic purpose, and because the focal entity is involved in a sensitive industry with negative news pending. The circles-ed information was collected and . 5311, et seq; 31 CFR Chapter X. The :nforma' . investigation or proceeding, or in tlie conduct nw: further released. disseminated. or transmit ?Writing: the BSA. See 31 U.S.C. a i;;rirninal, tax. or regulatory ..: . 3. ?311. The Information cannot Financial Crimes Enforcement Network United States Department ofthe Treasury BSAR Transcript BSA: and DCN: Narrative SAR SAR ?-WCM777--filed on 10/29/2013 reported on activity occurring between 07/22/2013 and 10/08/2013, totaling $6,016,331.03. ?=vsa The aggregate total of all SARs is $21 ,435,263.85 reporting on activity occurring between 04/18/2013 and 01/13/2014. <> - HSBC Hong Kong - WCM777 LIMITED ?Suspicious Activity Description? A timely review of the account in question indicates that activity similar to that reported in the initial occurred predating the initial SAR. Specifically, between 04/18f2013 and 06/28!2014 the focal entity was involved in 13 suspicious transactions totaling $200,400.00. The activity is suspicious as the relationship between the focal entity and the counterparties are unable to be determined. as well as having no discernable economic purpose, and because the focal entity is involved in a sensitive industry with negative news pending. Page 10 ?0?88 Financial Crimes Enforcement Network United States Department of?thc Treasury BSAR Transcript BSA: and DCN: Narrative A timely review of the account in question was conducted and it was observed that the activity leading to the writing of the initial SAR has been continuing. Specifically between 10/09/2013 and 01113/2014 the account in question conducted 1178 transactions totaling 15,218,532.82. The activity is suspicious as the relationship between the focal entity and the counterparties are unable to be determined, as well as having no discernable economic purpose, and because the focal entity is involved in a sensitive industry with negative news pending. All transactions and transaction details are listed on the attached Spreadsheet. Any information or documentation related to this report is available to any authorized law enforcement agency that requests it. Page 11 The enciosed information was collected and 5311. et seq: 31 CFR Chapter X. The investigation or proceeding, or in the conduct . rnlancorl diednminnmd rlipnimrml my?; men? of ?it: 'i?seasuly legulatinns implementing the ESSA, See 31 U.S.C. LI for 3. purpose consistent with a Imminal. tax. or regulatory fries 31 U.S.C. 5311. The information cannot hp ?=vsa